Yeager v. United States

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Yeager v. United States, 557 U.S. 110 (2009)

What happened
- Yeager was charged in a federal case with securities and wire fraud, insider trading, and money laundering related to a fiber-optic project tied to Enron.
- The jury acquitted Yeager on the fraud counts but did not reach a verdict on the insider-trading and money-laundering counts.
- After the acquittal on fraud, the government tried again on some of the insider-trading and money-laundering charges. Yeager asked the court to dismiss, arguing that the acquittals meant the government could not relitigate those facts.

The key question
- Does the Double Jeopardy Clause bar a new trial on charges that rest on the same facts as those the jury already acquitted of, when the jury’s verdict on all counts was inconsistent (one part acquitted, another part hung)?

The Supreme Court’s ruling
- Yes. The Court held that when a jury acquits on some counts and is hung on others, the government cannot relitigate facts that were necessarily decided by the acquittals. This follows the principle in Ashe v. Swenson.
- In Yeager’s case, the jury’s acquittal on the fraud counts necessarily decided that Yeager did not possess material, nonpublic information about the project. Therefore, arguing and retrying insider-trading and money-laundering charges based on that same information would violate the Double Jeopardy Clause.

Why it matters
- The decision clarifies that a jury’s acquittal on certain charges can have the same preclusive effect on related charges in a future prosecution, preventing relitigation of the underlying facts that were essential to the acquittals.